SPECPRO Probate Court’s Jurisdiction

Intestate Estate of San Pedro y Esteban v. Court G.R. Nos. 103727 & 106496, 333 PHIL 597-637
of Appeals Date: December 18, 1996
Ponente: HERMOSISIMA, JR., J.
INTESTATE ESTATE OF THE LATE DON COURT OF APPEALS (Second Division),
MARIANO SAN PEDRO Y ESTEBAN, AURELIO OCAMPO, DOMINADOR D.
represented by its HEIR-JUDICIAL BUHAIN, TERESA C DELA CRUZ,
ADMINISTRATOR, ENGRACIO F. SAN respondents-appellees.
PEDRO, petitioner-appellant.
DOCTRINE
A probate court's jurisdiction is not limited to the determination of who the heirs are and what shares
are due them as regards the estate of a deceased person. Neither is it confined to the issue of the validity
of wills. We held in the case of Maningat v. Castillo, that "the main function of a probate court is to
settle and liquidate the estates of deceased persons either summarily or through the process of
administration." Thus, its function necessarily includes the examination of the properties, rights and
credits of the deceased so as to rule on whether or not the inventory of the estate properly included them
for purposes of distribution of the net assets of the estate of the deceased to the lawful heirs. In the case
of Trinidad v. Court of Appeals, we stated, thus: "questions of title to any property apparently still
belonging to estate of the deceased maybe passed upon in the Probate Court, with the consent of all the
parties, without prejudice to third persons" Parenthetically, questions of title pertaining to the
determination prima facie of whether certain properties ought to be included or excluded from the
inventory and accounting of the estate subject of a petition for letters of administration, as in the intestate
proceedings of the estate of the late Mariano San Pedro y Esteban, maybe resolved by the probate court.
FACTS
The most fantastic land claim in the history of the Philippines is the subject of controversy in these two
consolidated cases. The heirs of the late Mariano San Pedro y Esteban laid claim and have been laying
claim to the ownership of, against third persons and the Government itself, a total land area of
approximately 173,000 hectares or "214,047 quinones," on the basis of a Spanish title, entitled "Titulo
de Propriedad Numero 4136" dated April 25, 1894. The claim, according to the San Pedro heirs, appears
to cover lands in the provinces of Nueva Ecija, Bulacan, Rizal, Laguna and Quezon; and such Metro
Manila cities as Quezon City, Caloocan City, Pasay City, City of Pasig and City of Manila, thus affecting
in general lands extending from Malolos, Bulacan to the City Hall of Quezon City and the land area
between Dingalan Bay in the north and Tayabas Bay in the south.

Petitioners-heirs, in G.R. No. 106496, on the one hand, contend that the lower court, then CFI, Bulacan,
Branch IV, had no jurisdiction as an "intestate court", to resolve the question of title or ownership raised
by the public respondent Republic of the Philippines, through the Office of the Solicitor General in the
intestate proceedings of the estate of Mariano San Pedro y Esteban.

The public respondent, on the other hand, invoking its sovereign capacity as parens patriae, argues that
petitioners' contention is misplaced considering that when the Republic questioned the existence of the
estate of Mariano San Pedro y Esteban, the lower court became duty-bound to rule on the genuineness
and validity of Titulo de Propriedad 4136 which purportedly covers the said estate, otherwise, the lower
court in the intestate proceedings would be mistakenly dealing with properties that are proven to be part
of the State's patrimony or improperly included as belonging to the estate of the deceased.
ISSUE/S
Whether the lower court's resolution of the question of ownership of the subject San Pedro estate in the
special proceedings case is proper.
RULING
YES. A probate court's jurisdiction is not limited to the determination of who the heirs are and what
shares are due them as regards the estate of a deceased person. Neither is it confined to the issue of the
validity of wills. We held in the case of Maningat v. Castillo, that "the main function of a probate court
is to settle and liquidate the estates of deceased persons either summarily or through the process of
administration." Thus, its function necessarily includes the examination of the properties, rights and
credits of the deceased so as to rule on whether or not the inventory of the estate properly included
them for purposes of distribution of the net assets of the estate of the deceased to the lawful heirs.

In the case of Trinidad v. Court of Appeals, we stated, thus:

". . . questions of title to any property apparently still belonging to estate of the
deceased maybe passed upon in the Probate Court, with the consent of all the parties,
without prejudice to third persons . . ."

Parenthetically, questions of title pertaining to the determination prima facie of whether

certain properties ought to be included or excluded from the inventory and accounting of the estate
subject of a petition for letters of administration, as in the intestate proceedings of the estate of the
late Mariano San Pedro y Esteban, maybe resolved by the probate court. In this light, we echo our
pronouncement in the case of Garcia v. Garcia that:

". . . The court which acquired jurisdiction over the properties of a deceased person
through the filing of the corresponding proceedings, has supervision and control over the
said properties, and under the said power, it is its inherent duty to see that the inventory
submitted by the administrator appointed by it contains all the properties, rights and credits
which the law requires the administrator to set out in his inventory. In compliance with
this duty, the court has also inherent power to determine what properties, rights and credits
of the deceased should be included in or excluded from the inventory. Should an heir or
person interested in the properties of a deceased person duly call the court's attention to
the fact that certain properties, rights or credits have been left out in the inventory, it is
likewise the court's duty to hear the observations, with power to determine if such
observations should be attended to or not and if the properties referred to therein
belong prima facie to the intestate, but no such determination is final and ultimate in
nature as to the ownership of the said properties."

In view of these disquisitions of this Court, we hold that the lower court did not commit any reversible
error when it issued the Order dated November 17, 1978 which set aside Judge Bagasao's decision dated
April 25, 1978 and declared Titulo de Propriedad No. 4136 as null and void, consequently excluding
all lands covered by the said title from the inventory of the estate of the late Mariano San Pedro y
Esteban.
VILLAROMAN